Yes, based on its text, history, and relevant Supreme Court precedent, although the Supreme Court has yet to definitively answer the question.

The Citizenship Clause of the Fourteenth Amendment to the U.S. Constitution provides that “[a]ll persons born or naturalized in the United States, and subject to the jurisdiction thereof, are citizens of the United States.” If a person is (1) born “in the United States” and (2) “subject to the jurisdiction” of the United States, then neither Congress nor the State Department has any power to deny that person recognition as a U.S. citizen.

 American Samoa has been a territory of the United States for 125 years – fully half the history of the United States itself. The United States has by treaty and statute confirmed the sovereignty of the United States over American Samoa. This followed Deeds of Cession in 1900 and 1904 whereby the traditional chiefs of these islands transferred sovereignty to the United States based on the understanding that they would be recognized as citizens and their land and culture protected. American Samoa is not part of any nation except the United States. 

On April 17, 2025, President Donald Trump commemorated the 125th anniversary of Flag Day in American Samoa in a video address to the people of American Samoa, declaring that “your beautiful Islands are a beloved part of the United States.” He explained: “The Chiefs who first chose to raise the Stars and Stripes over Samoa gave their descendants the greatest gift of all, the gift of being part of the Greatest Country in the History of the World.” The U.S. Department of Interior also announced: “Today we celebrate 125 years since American Samoa became part of the United States. For over a century, the stars and stripes have flown proudly over the Islands—a symbol of our shared history, heritage, and resilience.” 

American Samoa Governor Pulaali’i Nikolao Pula explained that “[Flag Day] is a sacred recognition of the covenant forged between our forebears and the United States in 1900,” emphasizing that “there is no American Samoa without the United States and there is no United States without American Samoa. We each bring something absolutely wonderful to each other.”

A person born in American Samoa is therefore “born … in the United States” for purposes of the Citizenship Clause. Moreover, because someone born in American Samoa “owes permanent allegiance to the United States,” a person born in American Samoa is also born “subject to the jurisdiction of the United States.” Accordingly, the Fourteenth Amendment provides that someone born in American Samoa, just like someone born anywhere else on U.S. soil, cannot be denied citizenship by the federal government.

More information can be found in Section III.A.1 of Michael Pese’s Motion to Dismiss and also this legal brief filed by prominent citizenship scholars from across the ideological spectrum.